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Re: Hydroponics, Aeroponics, Aquaponics, and Containers


"The maintenance of the fertility of the soil is the first condition of any permanent system of agriculture."
Sir Albert Howard, An Agricultural Testament, 1940


Early U.S. practitioners of “organic” systems of production emerged in the late 1930s and 1940s to challenge the post-World War II rush to industrialize agriculture through the so-called peacetime use of war time chemicals. Their dedication to building soil fertility and farm biodiversity deeply contrasted with the dominant agrochemical company narratives of the time such as “a good bug is a dead bug,” and “DDT is good for me.”1 These pioneers, most notably J.I. Rodale, were persuaded by the theories of Lady Eve Balfour2 and Sir Albert Howard3 that the maintenance of good health depends upon the preservation and improvement of the health of the soil. In fact, Rodale coined the phrase healthy soils, healthy people, healthy planet to serve as the rallying cry for farmers to ditch their synthetic and toxic inputs and join the new food and farming revolution. He viewed those who embraced organic as taking a “simple but revolutionary” act.4


In the same vein of the organic pioneers, drafters of the Organic Foods Production Act of 1990 (OFPA) clearly understood the importance of creating biologically diverse soils, rich in nutrients, and free from contaminants as the foundation of organic agriculture. This sentiment is reflected in the law and in all of those places in the Crops Subcommittee’s Discussion Document where they excerpted text about soil from the organic rule. In clear contrast to organic, hydroponic/soilless operations rely upon inputs to feed plants rather than building soil ecology, fertility, biodiversity, and organic matter, as demanded by OFPA.


Having watched and participated in debates about whether hydroponic systems and their various iterations can be certified organic, arguments in their favor appear spurious at best -- akin to trying to fit a round peg inside a square hole. This observation could not be made more evident than in the Crops Subcommittee’s document under “Discussion” “Arguments for Hydroponics.”5 The argument that “lack of tillage and extraction of nutrients from soil” is “a way to improve or maintain soil” is a far stretch and weak interpretation of the Rule (§205.203(a). So is the claim that “allowing proliferation of active biology”...”is equivalent to rotation or cover crops” (§205.203(b).


The final argument in favor of allowing hydroponics in organic states that “the requirement of rotations and cover crops to maintain or improve such surrounding soil organic matter would be inapplicable” – says it all. Hydroponics cannot meet this basic organic systems requirement contained in the organic regulations. Therefore, hydroponic practices and products should not be allowed to be certified organic.


Organic consumers look to organic farmers to be the stewards of the land. One of the reasons they buy organic food is because they expect organic farmers to protect and improve farm land and soil so that future generations can thrive and be food self-sufficient. I agree with previous commenters that organic systems contribute to “Longer term improvements such as the use of nitrogen fixing crops, cover crops for improved organic matter, and an overall regenerative system that protects water and wildlife as well as supporting biodiversity.”6 These fundamental organic practices that improve the soil for the longer term are completely absent from the hydroponic/soilless operations.


Since hydroponic methods do not and cannot comply with OFPA and the National Organic Program Regulations, their products must not be certified organic. As such, the NOP must take swift action to ensure that the organic label and organic seal do not continue to be used on products grown in those types of systems.

Even recognizing the difficulties certified organic hydroponic operations will face once it is determined that they do not meet the organic standards, an alternative label under OFPA for organic hydroponics is still unacceptable solution. Since hydroponic operations do not meet OFPA’s legal and regulatory requirements, they must not be allowed to be certified organic. This is an unfortunate situation that the NOP needs to address and resolve in consultation with all affected parties at the earliest opportunity.


Thank you for your consideration of these comments. Respectfully submitted,

Lisa J. Bunin, Ph.D. Director, Organic Advocacy


1 Allen, Will. 2008, The War on Bugs, Chelsea Green Publishing Company: Vermont.
2 Organic movement pioneer and founder of the UK Soil Association, which still exists today and remains a worldwide leader in the creation of organic agriculture theories, practices, and standards.
3 Organic movement pioneer and author of An Agricultural Testament, London, 1940:1956, The Other India Press: Goa, India. 4

5 NOSB April 2017 Proposals and Discussion Documents, p. 129. 6 Ibid, p. 131

Dr. Lisa Bunin is widely respected in the organic community for here advocacy work. She served as the Center For Food Safety representative to the National Organic Coalition for many years.
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